I Data protection declaration

his Data protection declaration clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as "Data") within our online offer and the related websites, functions and content, as well as external online presence, e.g. our Social Media Profile (hereinafter generally referred to as the "Online Offer"). With regard to the terminology used. "Processing" or "Responsible Person", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Responsible Person


Street, House: Dubai Silicon Oasis, Unit 010, IFZA Dubai - Building A1

City, Country: Dubai, United Arab Emirates

Types of processed data:

- Inventory data (e.g., names, addresses).

- Contact information (e.g., e-mail, phone numbers).

- Content data (e.g., text input, photographs, videos).

- Usage data (e.g., websites visited, interest in content, access times).

- Meta / communication data (e.g., device information, IP addresses).

Categories of affected persons

Visitors and users of the online offer (hereinafter we refer to the affected persons generally also as "users").

Purpose of processing

- Provision of the online offer, its functions and contents.

- Answering contact inquiries and communication with users.

- Safety measures.

- Coverage Measurements/ Marketing.

Used terms

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter the "affected person"); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to a characteristic such as a name, to an identification number, to location data, to an online identifier (e.g. cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

"Processing" means any operation performed with or without the help of automated procedures or any such operations associated with personal data. The term goes far and includes practically every handling of data.

"Pseudonymisation" means the processing of personal data in such a way that the personal data can no longer be assigned to a specific affected person without additional information being provided, in case such additional information is kept separately and is a subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.

"Profiling" means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or to predict aspects relating to job performance, economic conditions, health, personal preferences, interests, reliability, behavior, place of residence or relocation of that natural person.

"Responsible person" means the natural or legal person, public authority, establishment or other entities that decide alone or together with others the purposes and means of processing personal data.

"Processor" means a natural or legal person, public authority, establishment or other entities that process personal data on behalf of the responsible person.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Whenever the legal basis in the data protection declaration is not mentioned, the following applies: the legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual actions as well as the response to inquiries is Art. 6 (1) lit. b GDPR, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c GDPR, and the legal basis for processing in order to protect our legitimate interests is Article 6 (1) lit. f GDPR. In case that vital interests of the affected person or other natural person require the processing of personal data, Art. 6 (1) lit. d GDPR serves as a legal basis for that.

Safety measures

We take appropriate technical and organizational measures in accordance with Art. 32 GDPR, taking into account the state of the technic, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural person, to ensure a level of protection appropriate to the risk.

Measures include, in particular, protection of the confidentiality, integrity and availability of data by controlling of physical access to the data, as well as of the access concerning this data, input, disclosure, assurance of availability and separation. Additionally we have set up procedures to ensure the awareness of the rights concerned, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy default settings (Article 25 GDPR).

Collaboration with processors and third parties

In the context of our processing, we disclose data without any consent and without any notice to other persons and companies such as our employees, outsourced employees, contractors which we have to involve for the execution conditions of the main contract (customs brokers, insurance companies, carriers, freight forwarders, tax consultants, marine lines, warehouses, etc.), as well as the authority (state bodies) to which we have to disclose the Confidential information for the execution of conditions of the main contract (customs authorities, tax authorities, etc.), who have a reasonable need to know such Confidential Information for the Purpose and who by reason of their contract of employment or by reason of any other written agreement are bound by a non-disclosure obligation or by ethical standards of their profession.

If we engage third parties to process data on the basis of a so-called "orders processing contract", this is done on the basis of Art. 28 GDPR.

Transfers to third countries

As long as we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or this happens in the context of the claim of third party services or disclosure or transmission of data to third parties, this will only be done if it is aimed to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Conditionally to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. GDPR. That means the processing is made e.g. on the basis of specific guarantees, such as the officially recognized establishment of an EU relevant level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").

Rights of the affected person

You have the right to request a confirmation whether the related data is being processed and an information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.

You have according to Art. 16 GDPR the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.

You have the right to demand the obtainment of the data concerning you, which you have provided to us, in accordance with Art. 20 GDPR and request its transmission to other responsible person.

Furthermore you have the right according to Art. 77 GDPR to file a complaint with the competent supervisory authority.

Withdrawal right

You have the right to withdraw the granted consent in accordance with. Art. 7 (3) GDPR with effect for the future.

Right to object

You can object to the future processing of the data concerning you in accordance with Art. 21 GDPR at any time. The objection may be in particular made against processing for direct marketing purposes.

Cookies and right to object to direct marketing

"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, e.g. the contents of a shopping cart in an online shop or a login status are stored. The term "permanent" or "persistent" refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be stored if users visit it after several days. Likewise, the interests of the users, which are used for range measurement or marketing purposes, can be stored in such a cookie. A "third-party cookie" refers to cookies that are offered by providers other than the responsible person who manages the online offer (otherwise, if it is only their cookies, this is called "first-party cookies").

We can use temporary and permanent cookies and clarify this in the context of our privacy policy.

If users do not want cookies to be stored on their computer, they will be asked to disable the respect option in their browser's system settings. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be found in a variety of services, especially in the case of trackings, be explained on the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that then possibly not all features of this online offer may be used.

Deletion of data

The data processed by us is deleted or restricted in your processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this privacy policy, the data stored by us are deleted as soon as it is no longer required for your purpose and the deletion does not conflict with any statutory storage requirements. As long as the data is not deleted because it is required for other and legitimate purposes, its processing will be restricted. That means that the data is blocked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons.

According to legal regulations in Austria the storage takes place particularly for 7 years according to § 132 (1) BAO (accounting documents, receipts / invoices, accounts, receipts, commercial documents, statement of income and expenses, etc.), for 22 years in case of real estate and for 10 years in case of documents related to electronically supplied services, telecommunications, broadcasting and television services, provided to non-entrepreneurs in EU Member States.

Business-related processing

In addition we process

- Contract data (e.g., subject of the contract, term, customer category).

- Payment data (e.g., bank details, payment history)

from our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.


The hosting services that we use are for the purpose of providing the following services: infrastructure and platform services, computing capacity, storage and database services, security and technical maintenance services that we use to operate this online offer.

Here we process, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer according to Art. 6 (1) lit. f GDPR in connection with Art. 28 GDPR (conclusion of order processing agreement).

II. Confidential information

1. Definitions

1.1 "the Disclosing Party" means a Party communicating the Confidential Information to other Party («the Receiving Party») or any representative of the Disclosing Party who on behalf of the Disclosing Party shall communicate the Confidential Information to the Receiving Party.

1.2. "the Receiving Party" shall mean a Party receiving the Confidential Information from the Disclosing Party.

1.3. "the Confidential Information" shall mean any and all written, electronic, visual or oral non-public information and data such as technical or business data, personal data, documents, knowledge, know-how, samples, prototypes, software, test results or trade secrets disclosed by the Disclosing Party in connection with the Purpose, which is identified at the time of disclosure as being confidential with an appropriate reference in accordance with the medium used or would reasonably be expected by the Receiving party to be confidential based on the nature of the information contained therein and the circumstances in which the materials are provided. Confidential Information includes all copies, summaries and results in connection with the Purpose as well as the information about the existence and contents of the discussions, negotiations.

First of all, the Confidential information is information about buyers, prices, volumes, terms and directions of delivery of the supplied Goods.

2. Non-Disclosure

The Receiving party agrees to treat all received Disclosing party's Confidential Information as follows:

a) to use it exclusively for the Purpose. In particular, unless otherwise agreed by the Parties in writing, the Receiving party will not use any received Confidential Information neither directly nor indirectly for its own products and/or products with third parties (irrespective of whether such products are already existing or need to be developed),

b) not to make it accessible to third parties in any way or form without prior written permission of the Disclosing party,

c) to make it accessible only to those of its employees, outsourced employees, contractors who have a reasonable need to know such Confidential Information for the Purpose and who by reason of their contract of employment or by reason of any other written agreement are bound by a non-disclosure obligation or by ethical standards of their profession,

d) to treat it as confidential and to exercise the same degree of care as in respect of its own information of similar significance , however to exercise at least a degree of reasonable care,

e) to return to the Disclosing party or destroy, if there is no need to return it to the Disclosing party, any documents, their copies and other information medium containing the confidential information if the Receiving party no longer needs to use this information when providing services and after the end of intermediary services.

3. Exceptions

The obligations specified in paragraph 2 do not apply to Confidential Information the Receiving party can prove by documentary evidence that such information is or was accessible to the public, whereby the Receiving party is not responsible for such accessibility. However when Confidential Information consists in the confidential combination of several pieces of Confidential Information then the disclosure to the public of part(s) of such Confidential Information shall in no event and under no circumstances impact the confidential character of the other pieces of Confidential Information that have not been disclosed or of the Confidential Information as a whole.

The Receiving party may disclose the Confidential Information which must be disclosed because of a binding official or court directive (imperative provisions of the law). In such case the Receiving party will inform the Disclosing party in writing about such disclosure without undue delay and strictly limit the disclosure of the Confidential Information which is requested.

The Receiving party has a right to provide the Confidential information without any consent of and without any notice to the Disclosing party to the Receiving party's contractors, which the Receiving Party has to involve for the execution conditions of the main contract (customs brokers, insurance companies, carriers, freight forwarders, tax consultants, marine lines, warehouses, etc.), as well as the authority (state bodies) to which the Receiving Party has to disclose the Confidential information for the execution of conditions of the main contract (customs authorities, tax authorities, etc.).

4. Notice of Unauthorized Use

The Receiving party will notify the Disclosing party promptly upon discovery of any unauthorized use or disclosure of the Confidential Information or any other breach of this Agreement. The Receiving party will document such incidents in a detailed written notice, to enable the Disclosing party to take any reasonable and appropriate action to end such an incident as soon as possible and to minimize consequences .

5. Return

The Disclosing party can require in written from the Receiving party to return, erase or destroy in full, Confidential Information in hard copy and/or electronic form, including all copies and any samples which had been supplied. The Receiving party shall undertake the return, erasure or destruction within 30 (thirty) days of receipt of the request and shall confirm this in writing.

The aforementioned obligation to return, erase or destroy shall not apply to the Confidential Information or copies thereof which must be stored by the Receiving party according to provisions of mandatory law, provided that such Confidential Information or copies shall be subject to confidentiality obligations according to the terms and conditions set forth herein until returned and/or destroyed.

6. No Assignment

Any rights or obligations cannot be assigned by a Party, including by merger (whether that party is the surviving or disappearing entity), dissolution or liquidation proceedings, without the prior written consent of the other Party.

7. Compensation

The Receiving party agrees to indemnify the Disclosing party in full for any losses associated with the disclosure of the Confidential information to third parties without the Disclosing party's consent.

Applicable Law

Data protection declaration and provisions on Confidential information shall be subject to the substantive law in force in the Federal Republic of Austria without reference to its conflict of law provisions.

Settlement of Disputes

Any dispute between the Parties arising out of or in connection with Data protection declaration and provisions on Confidential information by a Party to the other shall be referred by either of the Parties to the jurisdiction of the Commercial court in Vienna Austria. The language of the trial shall be English.